Legal
Last Modified: October 23, 2024
This Privacy Policy (“Policy”) applies to the website, www.Flexip2p.in and/ or www.fincsquare.com (“Website(s)”) and cross platform mobile application software, “Flexip2pMobileApp” (“App”) facilitating credit lending and credit borrowing services (“Services”), developed, owned, operated and offered by FincSquare fintech Private Limited (“Company”). This Policy describes the Website, Platform and App’s use and sharing of information received from persons accessing or using the Services (“User”), such information being related to the Users or other persons downloading, accessing or using the App or Website. The Company adheres to the applicable laws regarding the collection, use, and retention of personally identifiable information (“Personal Data”) of the User.
By visiting the Website and/or downloading the App, the User hereby acknowledges and consents to the collection, use, disclosure and storage by the Company, of User’s own Personal Data received by the Company by virtue of the User’s usage of App/Website in the manner described in this Policy. In addition, the User also agrees to be bound by the terms and conditions of this Policy while using or accessing the App/Website. If the User does not agree with the terms of the Policy, he/ she should not access or use the App/ Website.
Information Collected From User
When User registers with the Website or App, the User may be asked to provide Personal Data including without limitation: (1) personally identifiable information, which includes any information about the User that could reasonably be used to identify him/her in person, such as User’s name, gender, business name, address, email address, date of birth, date of incorporation, any photo identity proof, address proof, phone number etc. (“Personal Information”); and, (2) financial information such as User’s income, credit/debit card details, bank details, financial accounts details, Credit Report information etc. (“Financial Information”). Personal Data shall also include the information of such third parties that the App/ Website may have access to during the course of providing the Services to the Users. The App/ Website may also collect recurring information of the User’s geographic locations on a continuous basis.
In addition to any Personal Data, that User chooses to submit to the Company, the Company and its third-party service providers may use a variety of technologies that automatically collect certain information, including but not limited to usernames, passwords, phone number(s), email ids, geographical location and other security and usage related information, whenever User visits or utilizes the Services (“Usage Information”). The Company also automatically receives and records information that User’s browser sends whenever User visits the Website/ App. Further, these server logs may include information such as User’s IP address or a unique identifiers of the device such as VPN, information of WIFI connectivity and such other information (“Device Identifier”), browser type, browser language, the date and time of User’s request, pages viewed, time spent on the Website or App and one or more cookies that may uniquely identify the User’s browser, from his/her computer or other device used to access the Services (the “Device”). A Device Identifier is a number that is automatically assigned to the User’s Device, used to access the Services, and the Company’s computers identify User’s Device by its Device Identifier.
In order to provide smooth and uninterrupted Services, the App shall periodically access the address book or contact list on User’s mobile phone/device to locate the mobile phone numbers of other Users. To ensure a better user experience, the App may also at times, access names stored in the User’s address book to ensure any incoming messages and push notifications via the SMS feature having a name associated with them. For example, if the App cannot access names on User’s address book, when a non – App user responds to a SMS sent from the App, the incoming reply will show the non- App user’s number and not the name.
1.4 The App/ Website uses data collection devices such as “cookies” on the User’s Device drive that assist the App/ Website in providing Services. The App also uses cookies to allow User to enter his/her password less frequently during a session. For example, the information provided through cookies may be used to recognize a User as a previous user of the App (so the User does not have to enter his/her personal information every time). Most cookies are “session cookies”. A Session cookie is temporary and is automatically deleted from User’s device at the end of a session. Users are always free to decline App’s cookies if the application permits, although in that case User may not be able to use certain features on X and User may be required to re-enter the user’s password more frequently during a session.
Use Of Such Information Collected
The App/ Website may use the Personal Data and other information collected for any of the following purposes:
- To effectively provide the Services to the Users;
- for the purposes of software verification or administering software upgrades;
- to allow the User to participate in surveys regarding Services;
- to maintain the quality of the Services and provide general statistics regarding their use;
- to deliver Services, including email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that the User may request; archival or backup purposes;
- to alert the Users about updated information and other such new or updated services that may be offered by other Users;
- to allow access to exclusive features or functionality of the App;
- and to launch and/or open other mobile applications installed on the User’s device based on functionality of App
Disclosure Of Personal Information
The Company shall not rent, sell, or otherwise provide Personal Data received from the User to third parties without consent of the User, except as described in this Policy or as required by law. However, the Company and its affiliates reserve the right to share, sell and transfer some or all of the Personal Data to other business entities should the Company, or its assets, plan to merge with, or be acquired by that business entity.
The App/ Website may share the Personal Data received from the User with the Company’s other corporate entities and affiliates in connection with matters relating to the consumption of Services by the User to help detect and prevent identity theft, fraud and other potentially illegal acts; correlated or multiple accounts to prevent abuse of Services; and to facilitate joint or co-branded services that the User request where such services are provided by more than one corporate entity other than the Company.
The Company may disclose Personal Data, if required to do so by law or regulation; to its legal counsel, law enforcement officers, governmental authorities who have asserted their lawful authority to obtain the information or where the Company has in good faith reasonable grounds to believe that such disclosure is reasonably necessary to enforce its Terms of Use or this Privacy Policy and the information could be useful in the investigation of unlawful activity.
The Company has implemented commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse, alteration and security of the Personal Data received from the User in the Company’s care. The Company’s security practices and procedures limit access to Personal Data on need to know basis only. Such measures may include, where appropriate, the use of firewalls, secure server facilities, implementing proper access rights management systems and processes, careful selection of processors, standard authentication and encryption policies for its servers and other technically and commercially reasonable measures.
Security Of Information Collected From Users
The User agrees and acknowledges that the Personal Data and other information are stored on the secured servers and/ or data centres that may be placed in India or outside India. The Company is committed to protecting the security of any Personal Data and uses reasonable efforts including a variety of security technologies and procedures to help protect such Personal Data from any unauthorized access, use or disclosure. The Company will take all reasonable measures in furtherance of the above commitment. However, the Company cannot guarantee that the Personal Data received from the Users and other information stored on the servers will be absolutely protected. Company’s systems and the communication networks through which User’s access the App/ Website may be subject to security breaches and failures due to circumstances beyond Company’s reasonable control. These may include computer “hacking”, data theft or and physical theft among others. In such situations, the Company will try to rectify the problems as soon as possible.
Any data destroyed shall be disposed of in a manner that protects the privacy of the Personal Data received by the App/Website from the User in an appropriate manner as per the industry standard practices and norms.
To ensure and maintain standards of data protection and information security, the Company complies with and maintains the International Standard IS/ISO/IEC 27001 on “Information Technology – Security Techniques – Information Security Management System – Requirements” in accordance with the Reasonable Security Practices and Procedures as stipulated under the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
Third Party Links
The User agrees to comply with all third party privacy policies, if any, applicable to the use of such applications or its services. The Company is not responsible for the User’s use of any third party product and/or service including the terms and conditions, privacy practices or the content of those linked websites or such third party product and/or service or violation and infringement of any third party rights, policies, terms and conditions in connection with access, download or installation of such mobile applications.
International Transfer Of Data
In the process of providing Services to its Users, the App/ Website may transfer the Personal Data and other information that it collects to affiliated entities or other third parties across borders, and from the User’s country or jurisdiction to other countries or jurisdictions around the world. The Users understand, acknowledge and consent to transferring information and permitting the transfer of information, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as the User’s jurisdiction. The User hereby consents to the transfer of his/ her information across countries or jurisdictions around the world.
Governing Law
The usage of the Services is exclusively governed by the laws of India and the jurisdiction of the courts in the State of Telangana. The Company expressly disclaims any implied warranties or liabilities imputed by the laws of any other jurisdiction.
Modifications
Any changes in this Policy by the Company shall be posted on the Website to reflect changes in its policy so that the User is always aware of what information the App collects, uses, and under what circumstances, if any, the App may disclose it. User should periodically review the abovementioned page for the latest information on the App’s privacy practices. Once posted, those changes are effective immediately. Continued access or use of the Application constitutes the User’s acceptance of the changes and the amended Policy.
Advertisements
The App/ Website may use third-party advertising companies to serve advertisements when the User contacts it. These companies may use information (not including name, address, email address, or telephone number of the user) about the User’s visits to this and other websites in order to provide advertisements about goods and services of interest to the user.
Security Precautions
To ensure and maintain standards of data protection and information security, the App will secure the information which the User provides in accordance with applicable laws and industry standards and technology to protect the loss, misuse, and alteration of the User’s information under Company’s control. Whenever the User changes or accesses his/ her account information, the App offers the use of a secure server. Once the user information is in the App’s possession, the Company adheres to strict security guidelines, protecting it against unauthorized access.
Questions/Grievances
Any grievances or questions regarding this statement should be directed to the following e-mail address: support@flexip2p.in